RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events

Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events

ML062370311
Person / Time
Issue date:	02/02/2007
Revision:	0
From:	Case M J NRC/NRR/ADRA/DPR
To:
References
RIS-07-002
Download: ML062370311 (6)

February 2, 2007

NRC REGULATORY ISSUE SUMMARY 2007-02:CLARIFICATION OF NRC GUIDANCE FOR EMERGENCYNOTIFICATIONS DURING QUICKLY CHANGING EVENTS

ADDRESSEES

All holders of operating licenses for nuclear power reactors, except those who havepermanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.

INTENT

The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory information summary(RIS) to clarify NRC guidance for making emergency notifications during quickly changing events in which the emergency classification changes before the notification is made to the offsite response organizations (OROs) and the NR This RIS requires no action or written response by addressees.

BACKGROUND

The Commission's regulations in Title 10 of the Code of Federal Regulations (10 CFR)Section 50.47(b) and Appendix E to 10 CFR Part 50, "Emergency Planning and Preparedness for Production and Utilization Facilities," require, in part, that power reactor emergency preparedness plans describe a standard four-level emergency classification scheme and that procedures are in place to notify OROs of the emergency condition The licensee's emergency response organization (ERO) is required to assess the emergency conditions, declare the appropriate classification, and notify the OROs of the emergenc Should the plant conditions deteriorate further, the ERO is to re-classify the event, declare the escalated emergency, and notify the ORO These requirements are intended to ensure timely ORO response and actions to protect the health and safety of the publi For timely ORO response to occur, the licensee must make timely and accurate classifications and notifications.Power reactor licensees are specifically required by Section IV.D.3 of Appendix E to have thecapability to notify responsible State and local government agencies within 15 minutes after declaring an emergenc This requirement applies to a licensee's initial declaration and any subsequent declaration of an escalated emergency classification.

SUMMARY OF ISSUE

Degrading plant conditions during a rapidly evolving event can cause an escalated emergencyclassification to be declared before the notifications for the previous (or initial declaration) are mad The NRC has become aware of at least one instance in which a licensee revised itsprocedures to state that it was permissible to restart the 15-minute notification "clock" if degrading plant conditions cause an escalation in the declared emergency while the notification for the previous declaration was in progres The procedure went on to specify that the 15- minute time requirement for the notification of the previous declaration does not apply and the notification is not made in these case Consequently, a notification could be delayed for up to 30 minute However, since the procedure doesn't limit the use of this "clock" restart, an initial notification may be further delayed if the emergency escalates again before a notification can be made. This notification protocol is not in compliance with the requirements of Appendix E as theprocedure change reduces the licensee's capability to notify State and local governmental agencies within 15 minutes after declaring an emergenc Since the OROs implement actions in a staged approach depending on the emergency classification level, deferring a required notification could reduce their ability to implement timely actions to protect the health and safety of the public.The NRC recognizes that there could be exigent circumstances for exceeding this 15-minutecriterion during an actual emergency response and the emergency preparedness cornerstone of the Reactor Oversight Program provides for this eventualit Nonetheless, the licensee is required by regulation to have the capability of making the notification within 15 minutes ofdeclaring an emergenc Licensees should ensure their notification procedures and EROtraining provide the capability for making notifications to State and local governmental agencies within 15 minutes after declaring an emergency, as required by Appendix E.Further, it is suggested the licensees consult with their offsite counterparts when structuring anapproach for handling notifications associated with rapidly evolving events to ensure that the approach addresses the ORO needs while complying with Appendix Acceptable approaches include:*If the plant condition degrades and a higher classification emergency is declared beforethe notifications are made for the lesser emergency declaration, the licensee should update the notification to reflect the higher emergency classification and complete the updated notifications within 15 minutes of the lesser emergency declaratio Note:Since the OROs will take actions consistent with the higher emergencyclassification, it is not necessary to identify the lesser classification in the updated notificatio However, the plant conditions that gave rise to the lesser classification should be identified, if still present, in the followup notifications.*If the notification cannot be updated and completed within 15 minutes of the lesseremergency declaration, the ERO should make the notification for the lesser emergency within 15 minutes of its declaratio The notification could contain the caveat that a change in classification was forthcomin In parallel, the licensee should prepare the notification for the higher emergency classification and make an additional notification within 15 minutes of its declaratio RIS 2007-02